Privacy Policy Of Personal Data Of Site Visitors
1. General Provisions
1.1 This Privacy Policy of personal data of site visitors (hereinafter referred to as the Privacy Policy) has been developed in accordance with the provisions of the Constitution of the Cyprus and other regulatory legal acts of the Cyprus.
1.2 This Privacy Policy uses the following concepts:
True Lowcode Technology, TLT — TRUE LOWCODE TECHNOLOGY LTD, a limited company registered and existing under the laws of the Republic of Cyprus under the number ΗΕ 430590.
Platform — “Junica” computer program, the copyright holder is TRUE LOWCODE TECHNOLOGY LTD.
Site — the True Lowcode Technology website located on the Internet at https://junica.io.
Site Administration — employees of TRUE LOWCODE TECHNOLOGY LTD authorized to manage the site and determining the composition of the personal data of site Users, the purposes of personal data collecting, their processing and storage.
Site user — an individual, a subject of personal data, who voluntarily registered on the site and provided the necessary personal data during registration.
Personal data — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data), which alone or in combination with other information available to the Site, allows identifying the Site User.
Processing of personal data — any action (operation) or a set of actions (operations) performed with the use of automation tools or without them with Personal Data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.
Application — a separate instance of the Platform where a User can create arbitrary derivative software products through customization. The application can be deployed both on the basis of the On-premises version and in the cloud version of the Platform.
1.3 This Privacy Policy establishes the procedure for obtaining, protecting, storing, processing and transferring the Personal Data of Site Users, and applies to all information that the Site Administration can receive about Site Users during their use of the Site.
This Privacy Policy does not apply to other sites and does not apply to third party sites. The Site Administration is not responsible for third-party sites that Site Users can visit following the links available on the Site.
1.4 The Personal Data of Site Users obtained on the Site includes: last name/surname, first name; telephone, email address; represented company, position in the company, industry of the company, country of location/country of origin, other similar information provided by the Site User, on the basis of which it is possible to identify him as a subject of personal data. And also, data that is automatically transmitted when browsing and visiting the Site pages: IP address, cookies information, browser information, access time, address of the page visited, referrer (address of the previous page).
1.5 The IP address is a unique locator used by electronic devices which allows them to be detected. When the Site user visit the Site, TLT can trace the IP address of the Site user’s device used to connect to the Internet and TLT may use this information to specify the general geographical location of the device and comprehend from which geographical areas the Site user is coming.
2. Purposes Of Personal Data Collection
2.1 The purposes for collecting Personal Data are:
— fulfillment of agreements to provide access to the Site, its Content and / or the Service, to the Service functionality, to administer the Site;
— identification when registering on the Site and / or when using the Service;
— provision of services, processing of requests and applications;
— establishing feedback, including sending notifications and requests;
— confirmation of the completeness of the provided personal data;
— confirmation of the completeness of the provided personal data;
— conclusion of contracts, mutual settlements;
— collection of statistics by TLT;
— improving the quality of the Site and / or its Service, the convenience of their use and the development of new features and services;
— conducting marketing (advertising) activities, sending offers by TLT and receiving them by User to promote TLT services on the market, including through direct contacts.
2.2 No processing of Personal Data incompatible with the given purposes is allowed.
2.3 To process Personal Data of the Site User, the Site Administration obtains the consent of the Site User.
3. Procedure And Conditions Of Personal Data Processing
3.1 The processing of Personal Data of Site Users is carried out solely for the purposes specified in Section 2 of this Privacy Policy.
3.2 The personal data of Site Users are stored electronically in the information system of the Site's Personal Data, as well as in archival copies of the Site's databases.
3.3 When storing the Personal Data of Site Users, organizational and technical measures are taken to ensure their safety and exclude unauthorized access to them.
3.4 The processing of Personal Data of Site Users can only be accessed by employees of the Site Administration who are allowed to work with Personal Data of Site Users and who have signed a non-disclosure agreement of Personal Data of Site Users.
3.5 The list of employees of the Site Administration who have access to Personal Data of Site Users is approved by order.
3.6 The processing of Personal Data on the Site is carried out in automated and non-automated ways.
3.7 The Site Administration may transfer Personal Data of Site Users to third parties only when necessary in order to prevent a threat to the life and health of Site Users, as well as in cases established by the legislation of the Cyprus.
3.8 In order to improve the quality of the service and ensure the possibility of legal protection, the Site Administration has the right to store log files about the actions performed by Site Users as part of the Site use.
3.9 Rules for the use of cookies and similar technologies:
3.9.1 Purpose of cookies
A cookie is a small piece of technical data that is stored on your computer and sent between your browser and the Junica server running the application.
The use of cookies allows the Junica application to:
— identify your work session;
— record your preferences (language version, time zone, etc.);
— identify the hardware and type of browser being used;
— collect navigational information to enable return;
— collect statistics of errors identified by users;
— collect statistics on testing and improving new functionality.
3.9.2 Cookies storage duration
The storage period for cookies depends on the nature of tasks performed. So, for example, a cookie record of the active session automatically becomes irrelevant at the end of the session and is deleted. Cookies will be automatically deleted from your computer as soon as the period necessary to run the appropriate tasks has passed.
TLT will also retain the User’s Personal Data for internal analysis purposes. The User’s Personal Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Platform, or TLT are legally obligated to retain this data for longer time periods.
3.9.3 Access to cookie information
Personal information collected by cookies placed on your device may be transferred to and processed by Junica and its authorized representatives.
TLT may disclose the Site user’s Personal Data in the good faith belief that such action is necessary to:
— comply with a legal obligation;
— protect and defend the rights or property of TLT;
— prevent or investigate possible wrongdoing in connection with the Site and Platform;
— protect the personal safety of users of the Site and Platform or the public;
— protect against legal liability.
3.9.4 When the Site user first visit Junica sites (personal account, workspace, forum, etc.), the Site user consents to the use of cookies will be requested. If the Site user has approved the use of cookies on one of the Sites, TLT will assume that the use of cookies on all Sites has been approved by the Site user.
4. Rights And Obligations Of The Site Administration
4.1 The Site Administration has the right to establish requirements for the composition of personal data of Site Users, which must be provided for the use of the Site, while the Site Administration is guided by this Privacy Policy, the Constitution of Cyprus, and other federal laws of the Cyprus.
4.2 The Site Administration does not verify the accuracy of Personal Data provided by Site Users, believing that they act in good faith and keep information about their Personal Data up to date.
4.3 The Site Administration is not responsible for the voluntary transfer by site users of their contact details, password or login to third parties.
4.4 The Site Administration is obliged, at its own expense, to protect the Personal Data of Site Users from misuse or loss in the way prescribed by the legislation of the Cyprus.
4.5 The User’s information, including Personal Data, may be transferred to and safely maintained on computers and/or servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from the Site user's jurisdiction.
The Site user's consent to this Privacy Policy followed by the User's submission of such information represents the Site user's agreement to that transfer.
TLT will take all steps reasonably necessary to ensure that the Site user's data is treated securely and in accordance with this Privacy Policy and no transfer of the Site user's Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of the User's data and other personal information.
5. Rights Of Site Users To Protect Their Personal Data
5.1 Site users, in order to ensure the protection of their Personal Data stored on the Site, have the right to:
— receive full information about their Personal Data, their processing, storage and transfer;
— designate their representatives to protect their Personal Data;
— demand the exclusion or editing of incorrect or incomplete Personal Data, as well as data processed in violation of this Privacy Policy and the legislation of the Cyprus.
6. Procedure For Destruction, Blocking Of Personal Data
6.1 In case of detecting an illegal processing of Personal Data when the Site users apply, the Site Administration is obliged to block the illegally processed Personal Data relating to these Site Users from the moment of such an appeal for the period of verification.
6.2 In case an inaccurate Personal Data is revealed when Site Users apply, the Site Administration is obliged to block the Personal Data relating to these Site Users from the moment of such an appeal for the verification period, if the blocking of Personal Data does not violate the rights and legitimate interests of Site Users or third parties.
6.3 In case of confirmation of the fact of inaccuracy in Personal Data, the Site Administration, based on the information provided by Site Users or other necessary documents, is obliged to clarify the Personal data within 7 (seven) working days from the date of submission of such information and remove the blocking of Personal Data.
6.4 In case of detection of illegal processing of Personal Data by the Site, the Site Administration, within a period not exceeding 3 (three) working days from the date of such detection, is obliged to stop the illegal processing of Personal Data.
6.5 In case it’s not possible to ensure the legality of Personal Data processing, the Site Administration, within a period not exceeding 10 (ten) working days from the date of detection of illegal processing of Personal Data, is obliged to destroy such Personal Data.
6.6 The Site Administration is obliged to notify the Site Users about the elimination of committed violations or the destruction of Personal Data.
6.7 If the purpose of Personal Data processing is achieved, the Site Administration is obliged to stop processing the Personal Data and destroy the Personal Data within a period not exceeding 30 (thirty) days from the date of achieving the purpose of Personal Data processing.
6.8 If the Site Users withdraw their consent to the processing of their Personal Data, the Site Administration is obliged to stop processing them and, if the storage of Personal Data is no longer required for the purposes of Personal Data processing, to destroy the Personal Data within a period not exceeding 30 (thirty) days from the date of withdraw.
6.9 In case it is not possible to destroy the Personal Data within a period specified in clauses 6.4. – 6.8. of this Privacy Policy, the Site Administration blocks such personal data and ensures the destruction of Personal Data within a period of six months, unless another period is established by the laws of Cyprus.
7. Service Providers
7.1 TLT may employ third party companies and individuals to facilitate the Site (“Service Providers”), to provide the Site or Platform on TLT behalf, to perform services or to assist us in analyzing how TLT's Site or the Platform are used.
7.2 These third parties have access to your Personal Data only to perform these tasks on TLT behalf and are obligated not to disclose or use it for any other purpose.
— cloud storage providers (Google, Zoho);
— data analytics providers (Facebook, LinkedIn, Google, Zoho);
— communication service providers (Zoho);
— marketing partners (in particular, social media networks, marketing agencies; Facebook, Google, Twitter, LinkedIn);
— Etc.
8. Children’s Privacy
8.1 TLT’s Site or the Platform does not address anyone under the age of 16 (“Children”).
8.2 TLT does not knowingly collect personally identifiable information from anyone under the age of 16. If the User is a parent or guardian and the User is aware that children has provided TLT with Personal Data, please contact TLT. If TLT become aware that TLT has collected Personal Data from children without verification of parental consent, TLT takes steps to remove that information from the Site or the Platform.
9. Changes To The Privacy Policy
9.1 This Privacy Policy may be changed or terminated by the Site Administration unilaterally without prior notice to Site Users. The new version of the Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Privacy Policy.
9.2 The current version of the Privacy Policy is located at https://junica.io.